Justia Civil Rights Opinion Summaries

Eric Holmes, an Indiana state prisoner, filed a lawsuit against the Marion County Sheriff’s Office under 42 U.S.C. § 1983, alleging unlawful imprisonment in violation of the Fourteenth Amendment. Holmes sought to proceed in forma pauperis, but the Prison Litigation Reform Act (PLRA) restricts this ability for prisoners who have had three prior civil actions or appeals dismissed as frivolous, malicious, or for failing to state a claim.The United States District Court for the Southern District of Indiana found that Holmes had incurred three strikes under the PLRA. The court determined that a previous case dismissed for failure to state a claim because it was barred by Heck v. Humphrey counted as Holmes’s third strike. Holmes did not contest the validity of his first two strikes. He filed a notice of appeal and moved to proceed in forma pauperis on appeal, but a motions panel of the Seventh Circuit denied his motion, identifying a different case dismissed due to judicial immunity as his third strike.The United States Court of Appeals for the Seventh Circuit reviewed whether dismissals based on affirmative defenses, such as those barred by Heck or due to judicial immunity, count as strikes under the PLRA. The court held that a case dismissed for failure to state a claim because it was barred by Heck counts as a strike if the Heck bar is clear from the face of the complaint. Similarly, a case dismissed on judicial immunity grounds incurs a strike if the immunity defense is clear from the face of the complaint. The court affirmed the district court’s dismissal of Holmes’s current suit, concluding that both the Heck dismissal and the judicial immunity dismissal counted as strikes. View "Holmes v Marion County Sheriff's Office" on Justia Law

In 2017, the Saginaw County Sheriff’s Office seized fourteen firearms during a domestic-violence investigation involving Benjamin Heinrich. Heinrich's uncle, Gerald Novak, and distant cousin, Adam Wenzel, claimed ownership of the firearms and sought their return. Sheriff William Federspiel refused to return the firearms, arguing that Novak and Wenzel had not proven ownership. Novak and Wenzel then sued Federspiel under 42 U.S.C. § 1983 and Michigan law, asserting various federal constitutional and state claims.The United States District Court for the Eastern District of Michigan granted summary judgment to Federspiel on all claims and denied Novak and Wenzel’s motion for partial summary judgment. The court found that qualified immunity protected Federspiel in his personal capacity and that Novak and Wenzel had not established constitutional violations. It also held that Michigan law does not recognize a cause of action to sue municipal officials for constitutional torts and that Novak and Wenzel could not establish the elements of claim and delivery.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court’s grant of summary judgment to Federspiel on the individual-capacity takings claims, procedural-due-process claims, substantive-due-process claims, Fourth Amendment claims, and inverse-condemnation claims. However, it vacated the grant of summary judgment on the official-capacity and injunctive-relief takings claims, official-capacity Second Amendment claims, and the claim-and-delivery action. The court remanded these claims for further proceedings, noting that Novak and Wenzel’s affidavits created a genuine issue of material fact regarding ownership of the firearms, and that the district court should address whether Federspiel’s actions were consistent with historical firearm regulation. View "Novak v. Federspiel" on Justia Law

Karyn Stanley, a firefighter for the City of Sanford, Florida, since 1999, was forced to retire in 2018 due to a disability. When she was hired, the City provided health insurance until age 65 for retirees with 25 years of service or those who retired due to disability. In 2003, the City revised its policy, limiting health insurance to 24 months for those retiring due to disability. Stanley, who retired under the revised policy, received only 24 months of health insurance.Stanley sued the City, alleging that the revised policy violated the Americans with Disabilities Act (ADA) by discriminating against those who retire due to disability. The district court dismissed her ADA claim, stating that the alleged discrimination occurred after her retirement, making her not a "qualified individual" under Title I of the ADA, as she no longer held or sought a job with the City. The Eleventh Circuit affirmed the district court's decision.The Supreme Court of the United States reviewed the case and affirmed the lower courts' decisions. The Court held that to prevail under §12112(a) of the ADA, a plaintiff must prove that they held or desired a job and could perform its essential functions with or without reasonable accommodation at the time of the alleged discrimination. The Court concluded that the ADA's protections do not extend to retirees who neither hold nor seek a job. The judgment of the Eleventh Circuit was affirmed, upholding the dismissal of Stanley's ADA claim. View "Stanley v. City of Stanford" on Justia Law

Carl and Roberta Culp filed a lawsuit alleging federal and state law claims against various defendants, including Fort Wayne and Allen County police officers. The claims included excessive force under 42 U.S.C. § 1983, intentional and negligent infliction of emotional distress, assault and battery, criminal mischief, and violations of the Rehabilitation Act and the Americans with Disabilities Act (ADA). The incident in question occurred on August 20, 2018, when Carl Culp, a double amputee, expressed suicidal intentions during a psychiatric appointment, leading to police intervention.The United States District Court for the Northern District of Indiana granted summary judgment in favor of the defendants on most claims, leaving only Carl Culp’s § 1983 excessive force claim and state law claims against Officers Woods and Schulien for trial. A jury found in favor of the defendants on all claims except for Roberta Culp’s state law battery claim against Officer Woods, awarding her nominal damages of $1. The Culps appealed the summary judgment decision, and Woods and Schulien cross-appealed the denial of costs.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that the district court did not err in granting summary judgment to the defendants, as the defendants’ brief complied with the local rules. The court also found that the Culps failed to present evidence of discrimination or failure to accommodate under the ADA and Rehabilitation Act. The court assumed, without deciding, that these laws applied to law enforcement actions but concluded that the evidence did not support the Culps' claims.Regarding the cross-appeal, the Seventh Circuit upheld the district court’s decision to deny costs to both parties, recognizing the mixed outcome of the case. The court affirmed the district court’s judgment in its entirety. View "Culp v. Caudill" on Justia Law

Donterious Stephens was present when Officer Juanita Mills arrested his mother, Mary Stephens, at her workplace. Donterious approached the scene and asked Officer Mills why his mother was being arrested. Officer Mills warned him not to walk up on her, and Donterious complied by standing back. After Mary was placed in a police vehicle, Donterious's father, Warren Stephens, was also arrested. Donterious then spoke to Officer Mills again, and she ordered his arrest. Donterious was arrested but not charged. Mary Stephens and another plaintiff sued Officer Mills, alleging that Donterious's arrest was unlawful.The United States District Court for the Eastern District of Arkansas denied Officer Mills's motion for summary judgment based on qualified immunity, finding that there were genuine issues of material fact regarding whether Donterious's arrest was lawful. Officer Mills appealed this decision, arguing that the undisputed material evidence showed she did not violate Donterious's rights.The United States Court of Appeals for the Eighth Circuit reviewed the case and denied the motion to dismiss the appeal for lack of jurisdiction. The court held that Officer Mills did not have actual or arguable probable cause to arrest Donterious for obstructing government operations. The court found that Donterious's mere presence at the arrest scene and his questioning of Officer Mills did not provide probable cause for his arrest. The court affirmed the district court's denial of summary judgment and qualified immunity for Officer Mills, concluding that Donterious's actions did not amount to obstruction under Arkansas law. View "Willis v. Mills" on Justia Law

Junius Joyner, III, an African-American male, was hired by a legal staffing agency, Mestel & Company (Hire Counsel), and assigned to work at Morrison & Foerster LLP in Washington, D.C. He worked on the merger of Sprint Corporation with T-Mobile U.S., Inc. from July to December 2019. Joyner alleged several incidents of racial discrimination and a hostile work environment, including delayed work assignments, derogatory comments, and harassment by coworkers. He also claimed wrongful discharge under D.C. law, asserting he was terminated after reporting potential antitrust violations.The United States District Court for the District of Columbia dismissed Joyner’s complaint for failure to state a claim. The court found that Joyner did not provide sufficient facts to support his claims of racial discrimination and a hostile work environment under 42 U.S.C. § 1981 and Title VII. The court also dismissed his wrongful discharge claim under D.C. law, concluding that it lacked supplemental jurisdiction over this state law claim.The United States Court of Appeals for the District of Columbia Circuit reviewed the case de novo. The court affirmed the district court’s dismissal of Joyner’s federal claims, agreeing that Joyner failed to plausibly allege that his treatment was racially motivated or that the work environment was sufficiently hostile. The court found that Joyner’s allegations did not meet the necessary standard to infer racial discrimination or a hostile work environment. However, the appellate court vacated the district court’s judgment on the wrongful discharge claim, holding that the district court lacked jurisdiction over this claim and remanded it with instructions to dismiss for lack of jurisdiction. View "Joyner v. Morrison and Foerster LLP" on Justia Law

Tony Clark was convicted of capital murder, attempted murder, and possession of a firearm by a previously convicted felon. His death sentence was affirmed by the Mississippi Supreme Court, and the United States Supreme Court denied his petition for writ of certiorari. Clark subsequently filed his first motion for post-conviction relief, claiming intellectual disability and ineffective assistance of counsel, among other issues.The Madison County Circuit Court initially reviewed the case, and the Mississippi Supreme Court affirmed Clark's convictions and sentence. Clark then sought post-conviction relief, which led to the current appeal.The Supreme Court of Mississippi reviewed Clark's motion for post-conviction relief. The court granted the motion in part, remanding the case to the Madison County Circuit Court for an Atkins hearing to determine if Clark is intellectually disabled, which would make him ineligible for execution under the Eighth Amendment. The court found that Clark presented sufficient evidence, including affidavits from medical professionals, to warrant a hearing on his intellectual disability claim. However, the court denied all other claims, including ineffective assistance of counsel related to mitigation evidence, Batson challenges, jury wheel issues, the avoiding arrest aggravator, jurors' racial bias, and jury instructions. The court also rejected Clark's cumulative error argument. The decision was to grant post-conviction relief in part and deny it in part. View "Clark v. State" on Justia Law

In this case, Olivia Boone, on behalf of her autistic son K.A., challenged the Rankin County Public School District's decision to move K.A. to a new program at a different school without her consent. Boone filed a complaint with the Mississippi Department of Education, alleging that the school district violated the Individuals with Disabilities Education Act (IDEA) by unilaterally making the placement decision. A hearing officer found that the school district violated the IDEA and ordered relief but denied Boone's request for compensatory educational services. Boone then filed a suit seeking compensatory educational services and attorneys' fees.The United States District Court for the Southern District of Mississippi affirmed the hearing officer's decision, holding that Boone was entitled to attorneys' fees but not compensatory educational services. Boone appealed the denial of compensatory educational services, and the school district cross-appealed the finding that it violated the IDEA and the award of attorneys' fees.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's judgment. The court held that the school district denied K.A. a free appropriate public education by failing to individualize his education plan to address his elopement tendencies and by predetermining his placement without Boone's input. However, the court found that Boone did not prove that Brandon Middle School was not K.A.'s least restrictive environment. The court also held that Boone was not entitled to compensatory educational services, as the district court did not abuse its discretion in limiting relief to address Boone's primary concerns. Finally, the court affirmed that Boone was a prevailing party entitled to attorneys' fees, as the relief awarded altered the legal relationship between K.A. and the school district and fostered the purposes of the IDEA. View "Boone v. Rankin County" on Justia Law

A group of current and former pretrial detainees filed a putative class action against Prince George’s County, Maryland, and 11 state court judges, alleging that their detentions and the policies leading to them were unconstitutional. The plaintiffs sought a declaratory judgment, injunctive relief, and compensatory damages, claiming violations of the Due Process Clause and the Maryland Constitution.The United States District Court for the District of Maryland granted judgment on the pleadings, concluding that the judges and the county had absolute immunity from the plaintiffs’ claims for damages and an injunction, and that a declaratory judgment could not provide meaningful relief. The district court dismissed the judicial defendants based on absolute judicial immunity and dismissed the claims against the county based on quasi-judicial immunity. Additionally, the district court dismissed seven plaintiffs who had been released from pretrial detention, reasoning that they would not benefit from any available remedy.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court vacated the district court’s dismissal of the judicial defendants but concluded that the dismissal should have been for lack of subject matter jurisdiction due to the absence of an Article III case or controversy. The court held that the judicial defendants were acting in an adjudicative capacity, not as adversaries, and thus there was no justiciable controversy. The court also reversed the district court’s dismissal of the claims against the county, holding that municipalities do not enjoy immunity from suit under 42 U.S.C. § 1983. The court remanded the case for further proceedings consistent with its opinion, including the reinstatement of the claims of the seven plaintiffs who had been released from pretrial detention. View "Frazier v. Prince Georges County" on Justia Law

In the spring of 2020, a woman with a history of severe mental illness was detained at the Bucks County Correctional Facility after an altercation with a neighbor. While in custody, she was allegedly subjected to repeated uses of force by corrections officers, including being pepper sprayed, handcuffed, and placed in a restraint chair on multiple occasions. The complaint asserts that these actions were taken as punishment for her inability to comply with directives due to her mental illness, and that she did not pose a threat to staff or other inmates. Her condition deteriorated significantly during her detention, leading to her eventual transfer to a mental hospital, by which time she was reportedly catatonic and unresponsive.Her parents, acting on her behalf, filed suit in the United States District Court for the Eastern District of Pennsylvania against Bucks County and various corrections officers, alleging violations of her constitutional rights under 42 U.S.C. § 1983. The District Court found that the complaint sufficiently alleged a violation of her Fourteenth Amendment right to be free from excessive force and denied the defendants’ motion to dismiss on qualified immunity grounds. The court reasoned that the complaint was not detailed enough to determine whether the right at issue was clearly established at the time of the alleged conduct, and that further factual development was necessary.On appeal, the United States Court of Appeals for the Third Circuit affirmed the District Court’s decision. The Third Circuit held that when a complaint plausibly alleges a constitutional violation but lacks sufficient detail to assess whether the right was clearly established, qualified immunity cannot be granted at the motion-to-dismiss stage. The court concluded that the defendants’ entitlement to qualified immunity was not apparent from the face of the complaint and remanded the case for limited discovery to develop the facts necessary for a proper qualified immunity analysis. View "Stringer v. County of Bucks" on Justia Law